This Privacy Policy governs the manner in which BIENT TECHNOLOGIES PRIVATE LIMITED and/or its subsidiaries
(“the Company”) collects, uses, maintains and discloses information collected from users of the website
www.cryptoniumx.com.

We at cryptoniumx.com (“we”, “us”, “Website” or “CryptoniumX”) respect your privacy. This Privacy Policy
applies to personal and non-personal customer information obtained by CryptoniumX through our Website
and lays down the approach through which CryptoniumX collects, uses, maintains and discloses information
collected from users (each, a “User”) of the https://www.cryptoniumx.com website (“Site”).

In the following Sections we set out:

• The general categories of data and types of personal data that we may process;

• The source of that personal data;

• The purposes for which we may process personal data; and

• The legal bases of the processing.

1. PERSONAL IDENTIFICATION INFORMATION

1.1. The Company may collect your personal information while you access the Site.. While opening an account
with us we may collect your contact information including name, address, phone, email, PAN details,
Aadhaar details, etc.; information regarding your transactions and trading; bank account; and information
pertaining to your IP address and the device or computer used by you for the purpose.

1.2. Users may, however, visit our Site anonymously. We will collect personal identification information
from Users only if they voluntarily submit such information to us. Users can always refuse to supply
personally identification information, except that it may prevent them from engaging in certain Site
related activities.

1.3. We may process your registration data ("registration data"). Registration data may include your
username and email address. The source of the registration data is you. Registration data is required
in order for you to be able to use the service. The legal bases for this processing are consent and
the performance of a contract between you and us and/or taking steps, at your request, to enter into
such a contract;

1.4. We may process your account data (account data"). Account data may include your full name, email
address, username, country and telephone number. The source of the account data is you. The account
data may be processed for the purposes of providing our services, ensuring the security of our users
and services, and communicating with you. Users may need to set their full name to their user profile
before buying bitcoins online from some sellers. Full name is only shown to bitcoin sellers with
whom user has opened trades. Verifying the full name helps protecting users against fraudulent payments,
increase user’s trustworthiness, and provides an alternative way to access user’s account information
in case the password is lost or the account is hacked. Phone number is used for notification purposes
and is an alternative mechanism to identify users in case the password is lost or account gets hacked.
The legal bases for this processing are consent; the performance of a contract between you and us
and/or taking steps, at your request, to enter into such a contract; and our legitimate interests,
namely the operation of our business model.

1.5. We may process your identity documents ("ID data"). Verifying account with an ID is currently mandatory
to all advertisers and users.. ID may contain your full name, country, date of birth, social security
number and gender. The purpose for ID data is to protect our users from fraud and helps us to prevent,
detect and investigate fraud, money laundering, criminal activity or other misuse of our service.
Moreover, by requiring all advertisers to ID verify will help us to provide a more trustworthy, safe
and reliable trading experience for our customers. ID creates a strong assumption about the ownership
of the account and thus ensures that we can return access to your account in case your account is
hacked. Legal bases for this processing are consent and legitimate interests of ours and/or by third-parties,
namely to prevent, detect and investigate fraud, criminal activity or other misuse of the services
and to prevent security issues.

1.6. We may process data about your use of our website and services ("usage data"). Usage data is primarily
non-personally-identifying information of the sort that web browsers, servers, and services like
Google Analytics typically make available, such as the browser type, language preference, referring
site, and the time of each visit. Other non-identifying information that we might have access to
includes how you use the service (e.g. search queries), your approximate location, cookies set by
our site, etc. Usage data may include:

a) Data that we collect mainly for behaviour statistics, business intelligence and email campaigns
("analytics data"). We gather website traffic data with the help of Google Analytics.

1.7. We may process data relating to your trades that you conduct through our website ("trade data").
The trade data may include trade ID, initiated trades, payment method, advertisement information,
buyer username, seller username, trade value (in fiat), trade value (in bitcoin), bitcoin price,
currency, timestamps of trade and trade chats as well as possible merchant invoice information and
ATM trade data. The source of the trade data is you and your trading partner. The legal bases for
this processing are consent; the performance of a contract between you and us and/or taking steps,
at your request, to enter into such a contract and our legitimate interests, namely the operation
of our business model.

1.8. We may process data relating to bitcoin transactions in and out of your accountt ("bitcoin transaction
data"). Information stored on received transactions may include timestamp, bitcoin amount, deposit
address (unique) and transaction ID and other publicly available data from the bitcoin blockchain.
Withdrawal transactions may include data such as timestamp, bitcoin amount, sent address, transaction
ID, and description. The source of the trade data is you and/or your trading partner. The legal bases
for this processing are consent; the performance of a contract between you and us and/or taking steps,
at your request, to enter into such a contract and our legitimate interests, namely the operation
of our business model.

1.9.. We may process information contained in or relating to any communication that you send to us or
what you generate through the use of our service ("communication data"). Communication data includes

a) all your messages, requests and other communication with our customer support which may happen
during the dispute review process or via support tickets, emails, or by means of any other communication
tool; and

b) all your communication and file attachments that you generate when conducting trades with other
users ("trade chat messages") or other data that you generated mainly by communicating to other
users. Communication data may include, email address, username, IP address, full name, audio
and video files and in the case of manual ID verification: photo of the user’s personal ID, photo
of the user, and photo of the user’s utility bill or related document. The communication data
may be processed for the purposes of communicating with you, record-keeping, in order to review
and resolve disputes, serve our customers better and improve our service. The legal basis for
this processing is our legitimate interests, namely the proper administration of our website
and business.

1.10. We may process information that you provide to us for the purpose of subscribing to our email notifications,
SMS notifications and/or newsletters ("notification data"). The notification data may include your
email address, phone number, username and full name. The notification data may be processed for the
purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing
is consent. You can unsubscribe at any point by contacting us or by clicking the unsubscribe link
in the email.

1.11. In addition to the specific purposes for which we may process your personal data set out in this
Section 3, we may also process any of your personal data where such processing is necessary for compliance
with a legal obligation to which we are subject, or in order to protect your vital interests or the
vital interests of another natural person.

1.12. All the aforementioned general categories of data may contain data that by itself does not identify
you and is therefore not deemed as personal data. Also, please try to avoid supplying any unnecessary
personal data to us.

2. WEB BROWSER COOKIES

Our Site may make use of “cookies” to increase and enhance users experience, for record-keeping purposes
and sometimes to track information, User’s web browser places cookies on their hard drive. User may
choose to set their web browser to refuse cookies, or to alert you when cookies are being sent.

b. Sensitive and private data exchange between the Site and its Users happens over a SSL secured communication
channel and is encrypted and protected with digital signatures.

c. We will not however, be liable for the following:

a. Breach by third party users where such breach is not due to our negligence or non-compliance with
law

b. Any appropriation of data pursuant to request from any governmental authority or any court

4. DATA RETENTION

We will retain your information for as long as is needed to provide you services, or as required to fulfill
our legal obligations. We will retain and use your information as necessary to comply with our legal
obligations, resolve disputes, and enforce our agreements.

By contacting us at [email protected] you can at any time obtain confirmation of whether or not personal
data concerning you is being processed.

You have the right to access and export your information at any time by sending a request to [email protected]

5. SPECIAL CASES

We take the protection of your personal information very seriously and recognise the need to keep your
personal information registered with the Site secure. Save as expressly provided herein, your personal
information will not be passed on by Us or by Our agents for use by third parties in any form whatsoever
unless We have obtained your consent or are legally required to do so or except for the following
purposes. It is Our policy not to use or share the personal information about Browsers or Members
in ways unrelated to those described in this Policy without also providing you an opportunity to
opt out or otherwise prohibit such unrelated uses. However, We may disclose personal information
about Browsers or Members (including all information and documentation provided to us concerning
a Member), or information regarding your use of the services or Site accessible through Our services,
for any reason if, in Our sole discretion, We believe that it is reasonable to do so, including but
not limited to:

a. To satisfy or comply with any laws, Act, regulations, or governmental, or legal requests for such
information;

c. To make reports concerning suspicious activity, potential money laundering, terrorism financing
or other potentially unlawful activity to law enforcement agencies, regulatory agencies and other
governmental agencies in any jurisdiction where we deem it appropriate in our sole discretion;

d. To disclose information that is necessary to identify, contact, or bring legal action against
someone who may be violating our Terms & Conditions or other User policies;

e. To operate Our Site and the App and Services properly;

f. To protect Ourselves, Our Members, and the general public, We specifically reserve the right to
disclose any and all information to law enforcement in the event that a crime is committed, is
suspected, or if We are compelled to do so by lawful criminal, civil, or administrative process,
discovery requests, subpoenas, court orders, writs, or reasonable request of authorities or persons
with the reasonable power to obtain such process;

g. It is further within Our sole discretion to cooperate with and disclose information to law enforcement,
private party litigants and governmental agencies, about Our Users to the extent required by
applicable law.

h. If We have reason to believe that a Member is not the owner of a credit card or other account,
even if the credit card or account use is authorized, We may provide information about you to
the credit card and/or account holder and/or appropriate authorities.

6. SHARING YOUR PERSONAL INFORMATION

We do not sell, trade, or rent Users’ personal identification information to others. We may share generic
aggregated demographic information not linked to any personal identification information regarding
visitors and users with our business partners, trusted affiliates and advertisers for the purposes
outlined above.

7. CHANGES TO THIS PRIVACY POLICY

We may periodically make changes to the Privacy Policy. While the Company will attempt to notify you
of these changes, it is your responsibility to review this privacy policy on regular basis and remain
informed of any changes.

8. YOUR ACCEPTANCE OF THESE TERMS

By using this Site, you signify your acceptance of this policy and terms of service. If you do not agree
to this policy, please do not use our Site. our continued use of the Site and the App following the
posting of changes to this policy will be deemed your acceptance of those changes.

9. CONTACTING US

In case of any doubts and queries regarding this Privacy Policy, the practices of this website, or your
dealings with this site, please do not hesitate to contact us at [email protected]